Opinion on the
scientific basis for import bans proposed by Austria with
regard to BSE risks in Germany and France adopted by the
Scientific Steering Committee at its meeting of 29-30 March
2001

1. INTRODUCTION

The Austrian authorities provided on 28
December 2000, a scientific justification for banning
imports of live bovines and bovine products from Germany.
The main justification is that these imports from Germany
could result in an "additional external challenge" for the
Austrian cattle system. This would be against the GBR
decreasing policy that the Austrian government is pursuing
by both increasing stability and reducing external
challenge.

On 22 January 2001, they provided an
additional scientific justification for the import ban
against France. It focuses on the "internal challenge" in
France since 1996, arguing that the SSC underestimated
it.

2. OPINION

The SSC considers that the opinion
previously expressed on the scientific basis for trade
restrictions proposed by Austria with regard to France also
applies to the present case. With regard to the additional
scientific justification the SSC wants to point out that no
such imports were recorded by the French authorities,
according to their dossier provided to the Commission
services in 1998/99 for the assessment of their GBR. If the
French Ministry of Agriculture did refer to illegal imports
it is clear that such imports could not have been taken
into account when assessing the GBR of France. However,
such imports would not significantly have modified the GBR
level of France. It should also be noted that similar,
unrecorded imports from BSE affected neighbouring countries
are likely to be experienced by all countries in such
situation.

It also agrees that the cattle imports
from UK to France in 1993-1995 could represent a high
external challenge. However, the French authorities
confirmed previously that these were exclusively calves for
veal-production. However, it retains its assessment that
the infection risk for French cattle decreased after 1996,
mainly because of the exclusion of SRM and fallen stock
from rendering that was implemented in France in that
year.

As far as embryos and semen are
concerned, the SSC reiterates its position that there is no
scientific justification to assume a risk from imports of
bovine semen, embryos and ova from any country, provided
the recommendations made in the SSC opinion of March 1999
are respected.

As far as to the recent reported
incidence of BSE in Germany and its evolution, it is
ascribed by the SSC to 3 factors :

Real increase in incidence as
predicted in its opinion on geographical BSE risk;

Recently introduced tests on
identifying cases that would not have detected
previously;

The improved passive
surveillance.

The domestic prevalence in Germany
(source : report on assessment of GBR of Germany, July
2000) results from the following factors :

During the 80s and early 90s a very
unstable German BSE/cattle system was exposed to
increasing external challenges, particularly between 1988
and 1993.

A significant challenge resulted from
importation of over 13000 cattle and more than 1000 tons
of MBM from the UK during the period when the UK epidemic
probably peaked. Imports of cattle and MBM (2000-17000
tons p.a.) from other countries affected by BSE added to
this external challenge, which increased to very high
levels between 1988 and 1993. Import of potentially
contaminated MBM via other EU-countries, e.g. included in
imported feedstuffs, cannot reliably be estimated.

Introduction of the BSE-agent during
this period and its subsequent amplification and
propagation is most likely.

After 1994 the risk of amplification
and propagation of the BSE-agent started to decline and
since 1996 the anticipated amount of circulating
BSE-infectivity is considered to be constant.

The BSE infectivity that was most
likely introduced in the very unstable system is assumed
to have led to an internal challenge that was amplified
until the system became neutrally stable in 1996."

The overall challenge in Germany
(source: report on assessment of GBR of Germany, July 2000)
is determined as follows:

It is assumed from the interaction of
the significant external challenge and the very low
stability that an internal challenge developed from 1990
onwards, at least partly balancing the reduction of the
external challenge after 1993.

Therefore the overall challenge
remained at very high levels after the external
challenges decreased. Since 1996 it is constant, when the
system became neutrally stable.

With the improved rendering (June
2000) and the exclusion of SRM (Oct. 2000) the system in
Germany is now stable.

The SSC underlines that the current
incidence figures do not require modification of the GBR
level of Germany or France as assessed in its GBR-opinion
of July 2000. However, this position will be reviewed
regularly in the light of the results of the intensified
surveillance.

In the above mentioned documents, the
Austrian competent Authority states, among other things,
that with a view to ensuring optimal stability against BSE,
Austria is strictly complying with the ban on feed and on
the use of specific risk materials. Moreover, the rendering
plants in Austria are meeting optimal conditions (i.e.
133°C/20 min/3bar).

Therefore, under such optimal conditions
of stability as declared by Austria (GBR level II), no
additional challenge would build up in the Austrian
BSE/Cattle system as a consequence of additional
infectivity deriving from imports of cattle or MBM from
Germany and France (GBR level III) and no additional
measures should be needed with regard to international
trade because there is no risk that the agent could enter
the Austrian BSE/cattle system.

Moreover, in deciding upon appropriate
measures, the possibility should have been considered of
slaughtering also cattle imported from Germany before
reaching an age at which the animals could harbour
significant levels of infectivity, as already foreseen by
Austria for cattle imported from France.

3. CONCLUSION

In conclusion, the SSC at this stage
does not consider the justification provided so far by
Austria as substantial enough to support the assumption
that the risk for Austrian consumers to be exposed to the
BSE agent would significantly increase due to imports of
live cattle from Germany or France.

As regards to the risk for Austrian
cattle to be exposed to the BSE-agent, no increase has to
be expected as long as the system is as optimally stable as
claimed by the Austrian Authorities. An optimally stable
system would prevent the agent from reaching domestic
cattle.